Martin B. Biles

8.

-4-

Enclosure VI shows the quantity of alpha wastes, assumed to

‘be 2391, dumped into the ocean during the last eight years
undor a prozram managed by the European Nuclear Energy

Agency.

Thus, the Interc tonal roticy is to allow ocean

dumping of limited quantities Gr rac:-Guctivity in a controlled

fashion and there is an agency to facilitate and coordinate
dumping by certain European nations.

The added features of the Act and EPA Rega., (compared to
International Regulations) which in our experience prohibits only
U.S. agencies from putting radioactivity into the ocean, are of
questionable value in protecting the ocean environment and are
of no wee in golving any waste Ciscosal protlems inthe U.S.

These

provisions are highly discriminatory agzinst the U.S. considering
thet other nations are dumping radioactive wastes into the occan.
Ocean dumping by other nations will presuincdly continue since

such actions are allowed under the International Reruletiens without
eo much ''rcd tape." Forccases such as clearup of“old radioactive

facilities and nuclear testing grounds, these resulations are in
conflict with our requirement to kcep exposures of people as low as
practicable. In this context, U.S. regulations have a negative benefit
for U.S. people.
As otated by Mr. Wastler in item 3c of Enclosure 1I".... if you have
a DEIS which stateg another feasible disposal method, it virtually
eliminates one of the requirements for an ocean dumping permit,
namely the lack of ak alternate disposal methed."' This statement
reveals probably the most serious difference of all between the Act
and EPA Regs., and between EPA Regs. and International Regulations.
The Act requires that the Administrator (of EPA) shall establish and

apply criteria for reviewing and evaluating permit application including

locations and methods cf disvosal and land-based alternztives, (see

Sec. 102(3)(G) of Enclosure Hil),

The Act does not state (if so I cannot

find it) that the existence of some cther alternative virtually climinztes

the possibility of obtaining a permit.

This is an EPA requirement

additional to the Act that goes far cutsido the requirements of the <\ct.
The International Regulations state that in the environmental assessment

that is to be made, consideration is to be given to the "justification for

the proposed dumping, when weighcd against land-based altcinatives, "'
Thus, the existence of other options, unde: these regulations, does

not rule out obtaining an ocean dumping permit if ocean dumping is the
bect alternative. The International Rerulations require that participating
nations evaluate variouy alternatives and do what is practical and reasonat

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